Riello S.p.A., belonging to UTC Climate, Controls & Security, and its subsidiaries and affiliates (collectively, “Riello”), are committed to protecting the privacy of visitors to its website (“Website”) and users of its mobile applications (“Apps”) as well as the Personal Information collected and processed from individuals separate and apart from its Website and Apps. It is important that our users understand how we collect, use and disclose Personal Information (as defined below).

This Privacy Notice describes our practices related to Personal Information collected through Riello websites and mobile applications and/or separately apart from this Websites and Apps, unless there is a separate privacy notice for a particular website or mobile application or other purposes. This Privacy Notice applies and is effective only in those cases in which the applicable privacy legislation imposes the obligation to provide it.

What Personal Information does Riello collect? How does it collect such Information?

“Personal Information” is information through which a natural person is identifiable or may be identified. Riello may collect, use and process your Personal Information in order to provide you with services, products or information that you request.

The collection of information will be transparent to you, and you will have the opportunity to decide whether or not to provide it. If you choose not to provide any of the Personal Information requested, Riello may be unable to complete your transaction, or provide the information, services or products you have requested. Riello may collect information, including Personal Information, from you when you submit a form or request, or register a product with Riello, such as: name, physical address, the company for whom you work, phone number, email address and fax number. Riello may also ask you to provide information about the product you are registering or the person/company that installed or maintains it.

Riello may also collect information through your use of our Websites or Apps, such as device identifiers, IP address, log files, and location data. Please see “How does Riello use cookies or other tracking technologies?” below for more information.

We might need to collect other information for a specific form, feature, or other service that you may use or request. The content of such information will vary depending on the method of collection and the specific purpose(s) for which the information is being collected:

For personnel of suppliers, vendors, and business customers

- Name, including given, family, middle, and any suffix (such as Junior or Senior)

- Identification information, such as an identification number (in whole or in part), government-issued driver’s license, passport, or other document – collected if and to the extent allowed under applicable law

- Work experience, education and job history, skill categories, licenses, certifications, memberships to and participation in trade associations or professional organizations, or authorization to perform a certain job

- Qualifications to serve as a vendor, such as conflicts of interest information

- Information about an individual’s job, including job title, department, and job function

- Information about an individual’s employer, including company name, company location, and country of incorporation

- Name of supervisor and assistant

- Training information

- Visitor information, including the time, date, and location of visits, information regarding a vehicle for parking purposes, and information necessary to maintain visitor logs and screening

- Environmental, health, and safety information

- Agreements, programs, and activities in which the individual participates

- Information collected through a voluntary survey or promotion or through use of a product, such as security system

- Listing of nominal gifts that may have been provided or received

For visitors to Riello systems and facilities and persons authorized to use Riello systems

- Name, including given, family, middle, and any suffix (such as Junior or Senior)

- Identification information, such as an identification number (in whole or in part), government-issued driver’s license, passport, or other document– collected if and to the extent allowed under applicable law

- Information collected through a voluntary survey or promotion or through use of a product, such as security system

- Warranty-related information, such as the type of product purchased, and information related to the servicing of a product

Why does Riello collect your Personal Information?

Our purpose in collecting this information is to provide customized services and content relevant to your specific needs and interests. Your information may be used by Riello to carry out our contractual obligations, authenticate you as a user and allow you access to certain areas of our Website, Apps or social media sites or allow you to apply for a position at Riello.

If you are applying for a job, evaluate your interest in and/or allow you to apply for employment with Riello;

Obtain your location data in order to provide requested information or services;

Protect against fraud or investigate suspected or actual illegal activity;

Screen against sanctions and antiterrorism lists as required by law;

Respond to a legitimate legal request from law enforcement authorities or other government regulators;

Develop new offerings, improve the quality of our products, improve and personalize user experience, and better prepare future content based upon your interests and those of our general user population; or

Personal Information of personnel of suppliers, vendors, and business customers may be used for:

Maintaining Enterprise Resource Planning (“ERP”) systems, workflow systems, and other information technology (“IT”) systems, including workflows to document Riello participation in professional organizations and provision or receipt of business gifts and hospitality

Vendor due diligence

Managing physical and information security, including

- Access controls and security for computer and other systems

- Internet, intranet, e-mail, social media, and other electronic system access

- Virus, intrusion, and insider threat scanning and analysis

- Facility access and safety

Disaster preparedness

Responding to situations involving a risk of health or safety, including an emergency

Backing up and recovering data

Overseeing location tracking, duration, and other telematics of certain Riello assets for management of services provided, security, safety and management of efficiency

Prosecuting and defending claims in litigation, arbitration, administrative, or regulatory proceedings, including but not limited to pre-dispute activity, evidence collection, discovery, litigation holds and e-discovery efforts

Responding to law enforcement and other government inquiries

Business planning, including planning for or executing mergers, acquisitions and divestitures

As required or expressly authorized by applicable law or regulation

Except where used in support of a contract with you or to fulfill a legal obligation, our use of your Personal Information will be only for legitimate business interests as set out above.

Where is Personal Information stored?

Because Riello, their parent company and United Technologies Corporation (“UTC”), are global companies with locations in many different countries, we may transfer your information from one legal entity to another or from one country to another within the Riello and UTC group of companies in order to accomplish the purposes listed above. These countries include, at a minimum, the United States, the member states of the European Union, Canada, andother countries, including some in Asia.We will transfer your Personal Information consistent with applicable legal requirements and only to the extent necessary for the purposes set out above. Within the UTC and Riello group of companies, information is transferred subject to the Binding Corporate Rules.

Riello relies on available legal mechanisms to enable the legal transfer of personal information across borders. To the extent that Riello relies on the standard contractual clauses (also called the model clauses) or Binding Corporate Rules to authorize transfer, Riello will comply with those requirements, including where there may be a conflict between those requirements and this Privacy Notice.

Does Riello use your Personal Information to send you promotional communications based on preferences and behavior?

Riello may use the Personal Information you provide to contact you about products, services, promotions, special offers, surveys, and other information based on your preferences and behavior that may be of interest to you. If you prefer not to receive such communications please use the “unsubscribe” function within the Website or App, or let us know by sending an email to privacy.compliance@riello.com Also, Riello will ensure that any marketing and promotional communications, sent by electronic means, or other method of communication will provide a simple method for you to opt-out or unsubscribe. Please note that if you unsubscribe from promotional communications, you may continue to receive communications about our account or transactions with us.

Does Riello share the information it collects?

Riello may share your Personal Information with our affiliated companies, such as companies in UTC’s group of companies, and/or companies in which Riello has control, through either direct or indirect ownership for the purposes set out above.

RIELLO will not sell or otherwise transfer or share your Personal Information outside of the companies identified above, except to:

Service providers, dealers, distributors, agents or contractors that RIELLO has retained to perform services on our behalf. RIELLO will only share your Personal Information with third parties whom RIELLO has contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal requirements;

Comply with legal obligations, such as in response to a legitimate legal request from law enforcement authorities, courts or other government regulators or authorities, among other things;

Investigate suspected or actual illegal activity;

Prevent physical harm or financial loss; or

Support the sale or transfer of all or a portion of our business or assets (including through bankruptcy).

Your personal information may also be maintained and processed by our service providers in the United States, the member states of the European Union, Canada, Asia, and in other jurisdictions.

How does RIELLO secure Personal Information?

RIELLO is committed to ensuring the security and integrity of Personal Information. RIELLO has adopted reasonable physical, electronic and managerial procedures to safeguard your Personal Information. However, due to the nature of Internet communications, we cannot guarantee or warrant that your transmission to us is secure.

How can you correct, change or delete your information held by RIELLO?

You may request to access, update, correct, change, or delete your Personal Information at any time. RIELLO will use reasonable efforts to timely update and/or remove information. To protect the user’s privacy and security, RIELLO will take steps to verify the user’s identity before making any requested change. To access, change, or delete your Personal Information, to report problems with the Website /Apps, to ask questions or to raise concerns, send an email to privacy.compliance@riello.com. Some of our Websites, Apps, and social media accounts allow you to make corrections directly at the site without need to further contact RIELLO.

Please note that while we will assist you in protecting your Personal Information, it is your responsibility to protect your passwords and other access credentials from others.

What should you understand about the third party links that may appear on this Website?

In some instances, RIELLO may provide links to non-RIELLO controlled websites, which RIELLO will make reasonable efforts to identify as such. RIELLO does not control such third party websites, however, and cannot be responsible for the content or the privacy practices employed by other websites. Furthermore, this Privacy Notice does not govern information collected about you by third parties.

How does RIELLO use cookies or other tracking technologies?

Cookies

RIELLO may use cookies on its Website. Cookies are small text files sent to and stored on users’ computers. We use cookies to allow the Website to recognize repeat users, facilitate users’ access to the Website, and allow the Website to compile aggregate data that will allow content improvements. Cookies do not damage users’ computers or files. If you do not want cookies to be accessible by this or any other RIELLO Website, you should adjust the settings on your browser program to deny or disable the use of cookies. However, denying or disabling cookies or similar technology may prevent you from accessing some of our content or using some of the features on the Website. RIELLO may also use cookies and similar technology placed by one of our business or advertising partners to enable RIELLO to learn which advertisements bring users to our Website.

In addition, RIELLO monitors user traffic patterns throughout its Websites according to a user's domain name, browser type, date and time of access, and pages viewed. Our Web servers collect the domain names but not the email addresses of visitors. This information is collected in order to measure the number of visitors to our Website and to determine which areas of the Website users find useful based upon the amount of traffic to particular areas. RIELLO uses this information to enhance users’ experience at the Website and to better prepare future content based on the interests of users.

Web Beacons

This Website may also use web beacons. A web beacon is usually a pixel on a website that can be used to track whether a user has visited a particular website to deliver targeted advertising. Web beacons are used in combination with cookies, which means that, if you turn off your browser's cookies, the web beacons will not be able to track your activity. The web beacon will still count as a website visit, but your unique information will not be recorded.

Information collected by web beacons may include IP address information (see below). Web beacon information is also used for:

Advertising and email auditing, and reporting;

Personalization;

Site traffic reporting; and

Unique visitor counts.

IP Addresses

An Internet Protocol (IP) address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.

RIELLO may collect and keep track of IP addresses to, among other things:

Maintain Website safety and security;

Restrict access to our Websites to certain users;

Troubleshoot technical issues; and

Better understand how RIELLO Websites are used.

Log Files

RIELLO (or third parties on behalf of RIELLO) may collect information in the form of log files that are recording Website activities and statistics about web users' habits.

Log files are used for internal purposes only. By using log files, RIELLO can constantly improve and customize their Websites and applications.

The entries help us gather, among other things:

Internal marketing and demographic studies;

A user’s browser type and operating system;

Information about a user’s session (such as the URL, the date and time our Website was visited and which pages and for how long were viewed on our Website); and

Other similar navigational or click-stream data.

Social Network Information

Social network information is any information that you permit a third party social network to share with third party application developers such as RIELLO. Social network information includes any information that is part of your profile on a third party social network. Such social network may include, but is not limited to, Twitter, Facebook, google+.

To find out how your information from a social network may be obtained by us (or other third party application developers), please go on the settings page of the relevant social network. Furthermore, you acknowledge that we may use your Personal Information to match information with a social network for advertising purposes.

RIELLO cannot make assurances about the security of information that you share with third parties, including information you share with social media sites.

For more information about cookies and other tracking technologies, click here.

How may RIELLO use location data?

RIELLO and UTC is a global provider of heating, ventilating, air conditioning and refrigeration systems. Our heating, ventilating, air-conditioning and refrigeration systems and services promote integrated, high-performance buildings that are safer, smarter and sustainable. As such, the following are some examples of when location data may be requested to provide some of the services that RIELLO has to offer:

To improve product capability

To determine which service technician is closest to a service call.

In all of these cases, RIELLO will ask permission to collect your location data and so the collection of this data will be transparent to you – you will have the opportunity to decide whether or not to provide your location data. If you choose not to provide your location data, RIELLO may be unable to provide the requested service or complete the requested transaction.

How long do we keep your Personal Information?

The Personal Information you provide to RIELLO is only kept for as long as it is reasonably necessary for the purposes for which it was collected, taking into account our need to comply with contractual obligations, resolve customer service issues, comply with legal requirements and provide new or improved services to users. This means that we may retain your Personal Information for a reasonable period after you stopped using the RIELLO Website or App. After this period, your Personal Information will be deleted from all systems of RIELLO without notice.

What additional information should specific users know?

Parents, Guardians, and Children: Our Apps and Websites are intended for visitors who are at least 18 years of age, or the age of majority in their jurisdiction of residence. RIELLO does not knowingly solicit information from, or market products or services to, children. If you do not meet the age requirements set out above, please do not enter your Personal Information on this or any other RIELLO Website or App.

Users from California: Annually California residents may request and obtain information that RIELLO shared with other businesses for their own direct marketing use within the prior calendar year (as defined by California’s “Shine the Light Law”). If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which RIELLO shared this information in the immediately preceding calendar year. To obtain this information, please send an email message to privacy.compliance@riello.com with “California Shine the Light Privacy Request” in the subject line as well as in the body of your message.

Users from the EU: You have the right to lodge a complaint with your national or state data protection authority, which may also be known as a supervisory authority. You also have the right to: (i) request access to and correction or erasure of your Personal Information; (ii) seek restrictions on; or (iii) object to the processing of certain Personal Information, and seek data portability under certain circumstances. To contact RIELLO about a request to access, correct, erase, object or seek restrictions or portability, please use the contact methods indicated at the end of this notice.

Users from the US: RIELLO does not collect Social Security Numbers through its websites. RIELLO does, however, collect Social Security Numbers where required by law, such as for tax and payroll purposes for its employees. When RIELLO collects and/or uses Social Security Numbers, RIELLO will take proper care by protecting confidentiality, limiting access on a need-to-know basis, and implementing appropriate technical safeguards and retention plans.

How might RIELLO change this Privacy Notice?

Riello may need to update this Privacy Notice. This Privacy Notice may be modified from time to time without prior notice. We encourage you to review this Privacy Notice on a regular basis for any changes. Substantive changes will be identified at the top of the Privacy Notice.

How can you contact RIELLO?

If you have any comments or questions about this Privacy Notice or to obtain information on the manner in which we or our service providers treat your personal information, or if there are other things we can do to maximize the value of this Website or App to you, please email privacy.compliance@riello.com. If you have questions about RIELLO’s privacy practices in general, please emailprivacy.compliance@riello.com.

In the event that you are located in a country that will be governed by the General Data Protection Regulation and would like to contact the local Data Protection Officer, please note that in your email and your inquiry will be directed to the appropriate person. If you wish to opt-out from sharing your Personal Information with us or have your Personal Information be removed, you should e-mail to privacy.compliance@riello.com.

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CONSENT TO DATA PROCESSING

As reported in the Privacy Notice provided to me by law, I hereby acknowledge that the performance of the activities of Riello involves the communication (and the related processing) of my Personal Information, and I hereby confirm that:

I have read and I consent to the terms and conditions set out in this Privacy Notice (I am aware that failure to provide the Personal Information will make it impossible for Riello to complete the transaction or provide the information, services or products requested by you).

I consent to the processing of my Personal Information for the analysis of my preferences and behaviors as better specified in the Privacy Notice provided to me .

I consent to receive promotional communications on products, services, events and promotions, by e-mail, telephone, mobile phone, SMS, mail. I can easily cancel my registration at any time. To unsubscribe send an e-mail to: privacy.compliance@riello.com.

I consent To the processing of particular categories of my Personal Information pursuant to article 9 (such as those suitable to reveal racial or ethnic origin, political opinions, religious or philosophical convictions, or union membership, genetic data, biometric data intended to uniquely identify a natural person, data related to the health or sexual life or sexual orientation of the person) of the general regulation on data protection for the purposes indicated in the Privacy Notice. To oppose the processing send an e-mail to: privacy.compliance@riello.com